SecProbe.io

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ASI Entertainment, Inc.
1/12 Candlebark Crt.,  Research,  Victoria,  3095,  Australia
Telephone : +61.3.9437 1028 . E-mail: info@asieinc.com

April 5, 2005

Mr D. R. Humphrey
Branch Chief
Division of Corporate Finance
United States Securities and Exchange Commission
Washington, D.C., 20549

Dear Mr. Humphrey

Re:	Commission File Number: 0-27881
In response to your letter dated March 3, 2005, we respond as follows:

Item 1.
Future filings will be amended

Item 2.
2003 AirTV Revenue
Revenue for consulting services provided to alliance party. This activity was
noted in filings at the time fees generated. This is not considered a core
activity of the company. The main cost of providing the services was covered
by management remuneration.
2004 AirOne
Revenue from G3CARS product. This is a software product developed by the
company and as such, does not have a cost of sale after development. The
interface with the airline customer's system required an interface to another
software system and the cost of that interface was taken up as a cost of sale
and the customer charged (which was taken up as revenue) for the cost.

Item 3.
No research development was carried out in the 2004 year. In future, should
research and development be carried out, it will be noted separately in the
statement of operations.

Item 4.
Software costs have been fully expensed as incurred. There was no unamortized
software costs in the balance sheet or amortization cost taken up in the
statement of operations for 2004.  The company will disclose policy in the
future.

Item 5.
Accounting policy is now to review accounts receivable at each balance date
and to make any allowance for non recoverability the directors and management
consider appropriate.  Any accounts receivable outstanding for 12 months from
the date of invoicing are to be written off.

Item 6.
The Company has formalized a pricing and revenue recognition policy,
effective January 1, 2005.

There are two ways ASI will generate income under its airline programs.
Firstly, under a revenue services agreement, ASI will generate revenue from
email and internet services which will be received by ASI which will then pay
an agreed commission to the respective airline. Payment for the services will
be received from credit card payments, and revenue will be taken up in the
period in which the services were provided. Secondly, under a software license
agreement, flight log services will be provided to airlines on the basis of an
agreed fee for each flight the service is used on. Airline customers will be
invoiced under the terms of each agreement and revenue taken up in the period
the revenue is generated. In regard to both services, the airline buys the
hardware and ASI may receive commission on the sale of the hardware, subject
to final contract negotiations. Revenue from such sales will be taken up in
the period the commission was generated.

With the RFID tags, ASI will sell hardware and supply the tags on an on-going
basis at prices determined by customer volumes. Revenue will be taken up in
the period in which hardware and tags are delivered to customers.

Item 7.
The arrangements for supply and sale described in the 10KSB outline how
management plan to, and have marketed the product/services to potential
airline customers. We do not think we can expand further on this description
at present.

If equipment is sold at a discounted price, the customer will receive title to
the equipment.

The value of the equipment to the client on a standalone basis depends on the
certification and specifications of the hardware and the operating approvals
held by the airline.

If equipment is supplied at a discounted price, the ongoing service agreement
would not include minimum purchase or use requirements.  The option to supply
equipment at a discounted price is purely an option.  We do not at present
have any arrangement to supply equipment at a discount.

Should the price of the equipment be discounted, ASI would be unlikely to sell
at less than cost price because of the profit margin in the equipment,.

ASI will invoice/receive revenue under the terms of its agreements with
customer airlines.  There would not be any need for special accounting
treatment of the transactions for revenue recognition.

Unit of accounting should be each airline contract, which may have various
components, but are interlocking. With the internet/email service, there would
not be an element of unearned income in the agreement.  After hardware has
been supplied, revenue will depend on the use of the system by airline
passengers. G3CARS revenue will be from a fee charged for each flight data is
transmitted, so again revenue is dependant on usage, not a locked in payment.

Item 8.
Revenues taken up in fiscal 2003 and 2004 were invoiced in those years.

Item 9.
In future filings, wording of Note 2. would be:

"As of June 30, 2004 the Company owed officers, directors, and related parties
$150,903 for management fees ($56,402) and directors' fees ($94,501).

The Company in 2004 and 2003 incurred expenses of approximately $173,000 and
$166,000 respectively to a company affiliated through common stockholders and
directors for management expenses. These expenses are normally taken up as a
liability, but at June 30 2004, $334,000 of the debt was converted to equity."

Item 10.
The other major asset type is moving map systems with a book cost of $364,465
at June 30, 2004, against which depreciation of $291,572 has been charged.
Note 4 will be changed in future filings to reflect this.

Item 11.
The airline industry usually requires useful life of avionics of 5 to 10 and
sometimes up to 20 years. In view of this, management felt that 5 years was a
reasonable term over which to write off the equipment on a straight line
basis. It should be noted that the equipment will likely be sold over the next
year and further depreciation will not be necessary.

Item 12.
The ACAMS is a network server that links the passenger's notebook computers
and the satellite communication system on the aircraft.

The ACAMS were acquired in September 1997. They have been written down for
impairment per the 2004 accounts by approximately $414,000.

The first units were placed in service with Alitalia and Saudi Arabian
Airlines for certification purposes. It is expected that installation of the
systems will commence in second half of 2005 as agreed under our contract
with Saudi Arabian Airlines.

ASI has had equipment installed and has conducted certification and flight
demonstrations of its system on board an Alitalia 767 and a Saudi Arabian
Airlines 747. As a result, certification has been received from the FAA for
those installations. As stated in the 10KSB, the certification is then
applicable to similar aircraft types and is then modified for other aircraft
types.

Item 13.
As noted in the Company's previous response, the methodology applied for
testing for impairment was the future cash flow method described in SFAS 144,
paragraphs 16 - 21. The possibility of technological change and airline
industry downturn were considered by the Company and auditor as part of
discussions involving the possible need to impair the ACAMS assets. The
Company does not charge an arbitrary amount each period, but rather
re-evaluates the relevant issues each period (the most relevant being the
amount of time the equipment has been on the books without yet being
installed), and makes a determination of whether or not some type of
impairment is reasonable.  As noted in the Company's previous response, the
Company feels that no writedown at all was necessary, but the auditor felt
otherwise. The Company does not believe that the equipment will be worthless
in two years.  A contract has now been signed with Saudi Arabian Airlines and
it is expected that the ACAMS equipment will be installed and used on their
flights, and therefore the Company might have no more impairment writedowns on
the ACAMS.

Impairment analysis without cash flow analysis:
We note from SFAS 144, paragraphs 16 - 21, that just because a piece on
equipment is not currently generating cash, is not indicative in and of itself
that the equipment must be impaired, otherwise any piece of equipment not yet
currently installed would automatically and immediately be impaired. As set
forth in SFAS 144, 16-21, cash flow analysis testing is based on estimates of
future cash flows as reasonably determined, whether the equipment is currently
in service or not.

Item 14.
We acknowledge managements responsibility for the financial statements.

Item 15.
We are not privy to the decision making process of our investors, we can only
assume that they saw benefit in the options.

Stock purchased by investors - 756,074 shares at a price of 50 cents per share.

A Black Scholes calculation was made and a cost of $193,490 was taken up for
the issue of the options in the statement of operations.

Purpose of the stock issuance was to raise working capital for the company.

No purchasers of stock were employees exercising previously granted stock
options,

No options were issued at the same time the shares were repurchased.

Item 16.
612,500 shares and 60,000 shares were issued to McBain & Co Investment
Services in 2003 and 2004 respectively at a nominal value of $0.50 per share
for corporate advisory and capital raising services.

250,000 shares were issued at a nominal value of $0.50 per share in 2004 to
Searchlight Securities for legal services.

Please contact me if you have further questions.

Yours sincerely

/s/ Philip Shiels

Philip Shiels
Chief Financial Officer
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